`
`By: Michael P. Chu, Reg. No. 37,112
` McDermott Will & Emery
`
`227 W. Monroe, Ste. #4400
`
`Chicago, IL 60606
`
`Phone: 312-984-5485
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`Solenis LLC
`
`Petitioner,
`
`v.
`
`Ecolab USA,
`
`Patent Owner
`
`_____________________
`
`Inter Partes Review No.: IPR2016-1281
`
`U.S. Patent No. 8,465,623
`
`
`
`PETITIONER’S MOTION TO SEAL ITS OPPOSITIONS TO
`PATENT OWNER’S MOTION TO DISQUALIFY DR. DAVID DYER AND
`PATENT OWNER’S MOTION TO SEAL
`
`
`
`
`
`
`Petitioner seeks the sealing of certain documents pursuant to 37 C.F.R. §§
`
`42.14 and 42.54(A). Specifically, Petitioner requests that Board seal its Opposition
`
`to Patent Owner’s Motion to Disqualify And Strike the Petitioner’s Expert, Dr.
`
`David Dyer. Petitioner further requests that the Board seal its Opposition to Patent
`
`Owner’s Motion to Seal Exhibits 2002-2004, 2010-2011, Portions of Exhibits
`
`2007-2008 And Motion. Patent Owner has contended that the documents it seeks
`
`to seal contain information regarding “(1) its confidential processes and
`
`information shared with International Paper under Nondisclosure Agreements and
`
`(2) the details of development and testing of filler pretreatments.” (Paper 11 at p.
`
`2).
`
`While Petitioner disagrees with this characterization of the documents, they
`
`are sealed at present, pending Petitioner’s Opposition to Patent Owner’s Motion to
`
`Seal filed concurrently herewith. Because Petitioner must rely on the motions and
`
`exhibits submitted by Patent Owner that are currently sealed in opposing those
`
`motions, Petitioner seeks to temporarily seal its oppositions pending a Board
`
`decision on its Opposition to Patent Owner’s Motion to Seal.
`
`
`
`1
`
`
`
`Dated: September 20, 2016
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Michael P. Chu
`Michael P. Chu
`Kevin P. Shortsle
`McDermott Will & Emery LLP
`227 West Monroe Street, Suite 4700
`Chicago, Illinois 60606
`Phone: 312.372.2000
`Fax: 312.984.7700
`mchu@mwe.com
`kshortsle@mwe.com
`
`Attorneys for Petitioner Solenis LLC
`
`
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that a true and correct copy of PETITIONER’S MOTION
`TO SEAL ITS OPPOSITIONS TO PATENT OWNER’S MOTION TO
`DISQUALIFY DR. DAVID DYER AND PATENT OWNER’S MOTION TO
`SEAL was served via email on September 20, 2016 upon:
`
`
`
`
`Anthony R. Zeuli
`tzeuli@merchantgould.com
`MERCHANT & GOULD
`3200 IDS Center
`80 South Eighth Street
`Minneapolis, MN 55402
`
`
`
`
`
`DM_US 76225331-1.098680.0012
`
`
`/s/Michael P. Chu
`Michael P. Chu
`
`
`
`
`
`
`
`3
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